I am repainting relatively new siding on a pre-1978 home. The siding was installed after 1978 but was nailed over the top of the old lead-based exterior paint. Must I comply with the Rule?

The RRP Rule only applies when a painted surface is disturbed. If the repainting activity disturbs a painted surface, such as by sanding or scraping in preparation of painting, then the RRP Rule applies. The same is true even if you do not believe the old lead-based paint is disturbed when the new siding is prepared and repainted.

You also have the option to test the new siding to determine that it is free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight. This determination can be made by a certified inspector or risk assessor or by a certified renovator using an EPA-recognized test kit. If such a determination is made, then the RRP Rule does not apply.